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|October 12, 2012||Court overruled NameCheap's demurrer. NameCheap still refuses to respond to discovery.|
|August 24, 2012||Filed a motion to compel further responses to my second set of interrogatories propounded upon NameCheap. It only asked for the list of the domain names they provide WhoisGuard for.|
Filed a motion to compel the deposition of Raquel Khazanedar. She has no defense to her failure to appear, as she neither objected nor respond to my letter to her asking about her failure to appear.
|August 14, 2012||Filed 4 Motions to Compel Further Responses against Even though NameCheap waived objections, by not responding in time, the responses consisted solely of objections. NameCheap's primary objection is that they are immune from prosecution, therefore they do not have to respond to discovery.|
|July 13, 2012||Raquel Khazanedar did not appear at a properly noticed deposition.|
|July 11, 2012||Filed a demurrer to the answer of Nadar Khazanedar, as it contains boilerplate and nonsensical affirmative defenses. In California when filing an answer to a well pled verified complaint, you must answer with the same level of pleading -- meaning you can't just give boilerplate answers without any facts behind it.|
Also, filed a motion to strike the answer and enter default or in the alternative enter a judgment on the pleadings. Nadar Khazanedar's attorney, David Gold, had already admitted, uder oath, admitted that the complaint is true. Since Gold admitted that the complaint is true, there is nothing to dispute.
|July 5, 2012||Nadar Khazanedar filed an amended answer. Almost identical to the prior answer, but this time the attorney verified the answer, instead of admitted that the complaint is true. Why would the attorney verify the answer, unless Nadar Khazanedar has something to hide? This practice is frowned upon under California law, because the Courts are suspicious when the party fails to swear under oath that a pleading is true.|
|June 11, 2012||Default entered against Raquel Khazanedar.|
|July 6, 2012||Filed a demurrer to the answer of Nadar Khazanedar, as it contains boilerplate and nonsensical affirmative defenses. In California when filing an answer to a well pled verified complaint, you must answer with the same level of pleading -- meaning you can't just give boilerplate answers without any facts behind it.|
Also, filed a motion to strike the answer and enter default or in the alternative enter a judgment on the pleadings. Nadar Khazanedar's attorney, David Gold, admitted that the complaint is true. Since Gold admitted that the complaint is true, there is nothing to dispute.
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|July 1, 2012||Defendant NameCheap filed a demurrer against Plaintiff's complaint. NameCheap is being sued as the owner of some of the domain names being advertised, WhoisGuard. NameCheap is claiming immunity under 47 USC 230 because it is a registrar. However, courts have ruled NameCheap that WhoisGuard is outside of its role as registrar and therefore not entitled to immunity.|
|June 28, 2012||NameCheap served responses to discovery. All objections, claiming that it is not responding because it is immune from lawsuit. However, it had waived all objections, because it had missed the discovery response deadline.|
|May 31, 2012||Default entered against Build4Future, LLC. |
|May 24, 2012||David Gold, Nadar Khazanedar's attorney, admitted that the allegations in the complaint is true.|
Nadar Khazanedar filed an answer, but left his wife, Melissa Khazanedar, and daughter, Raquel Khazanedar to fend for themselves. Nadar does not verify the answer, but has his verified that my complaint is true.
|April 23, 2012||Added the names, Build4Future, LLC Nadar Khazanedar, Melissa Khazanedar, and Raquel Khazanedar as Does.|
| ||Went down the the address they have listed on the web site for the business. It is not a real address, but at the UPS store. I examined the records of the UPS store and found that there is no Nauder Khazan, but the name on his drivers license is really Nadar Khazanedar. The name of the company is really Build4Future, LLC, a Nevada LLC. The officers of Build4Future, LLC, are Nadar Khazanedar, Melissa Khazanedar, and Raquel Khazanedar. If Alivemax is why wouldn't they use their real names and identify the company? Legitimate businesses don't hide.|
|April 5, 2012||Filed the First Amended Verified Complaint to include NameCheap, and Alivemax's other name, stiforp.|
|March 16, 2012||Filed a the original verified complaint.|
|January 1, 2012||Sent a certified letter complaining of spam to Nauder and Melissa Khazan. According to their web site, they founded Alivemax. There is no such entity as Alivemax registered with the state of California. |
|January 1, 2012||In 2011, I started receiving spam advertising Alivemax. Alivemax seems to be a multi-level marketing scheme for vitamin supplement This spam was to a unique e-mail address I used with only one unrelated company. Then, I got similar spam for Stiforp, which looks like a multi-level scheme to market Alivemax. |
Alivemax.com, according to the whois information is owned by "Nutri Max Ltd" at 5753 G Santa Ana canyon Road Unit #512 Anaheim Hills, CA 92807. However, there is no Nutri Max Ltd registered anywhere in the United States, according to Knowx.com. I found out that the the address was not a legitimate address. Stiforp.com, on the web site states that its address is also the same as Alivemax's address. However, the whois information on stiforp.com states that stiforp.com is owned by NameCheap.
Why would any legitimate business lie about the names of the people who run it? Why would any legitimate business lie about it's real address? Why would any legitimate business hire NameCheap to hide its identity.